The IIF has made a formal submission to the International Organization of Securities Commissions (IOSCO) responding to IOSCO’s January 17, 2022, consultation report on measures to address the risks from the digitalization of retail marketing and distribution of financial services and products. IOSCO noted that developments in digital offerings can give rise to regulatory and investor protection challenges that span the distribution chain. In our submission, the IIF said: 

• The IIF agrees with IOSCO’s regulatory objectives to ensure effective regulation taking into account the challenges emerging from increased digitalization of marketing and distribution. 
• Implementation needs to be principles-based and technology-neutral and should retain room for innovation.
• The IIF also believes that existing cross-border and compliance rules across jurisdictions are sufficient; however, the IIF would support further measures and tools (e.g. use of AI in SupTech applications) to enhance supervision, regulatory cooperation and coordination, and enforcement.
• Regulators need to ensure the principle of “same activities, same risks, same regulation” is applied in the marketing and distribution of financial services as between regulated market participants and those outside the current scope of financial regulation. 
• Regulators may also consider the responsibility of online platforms, which may contribute to problematic market practices as described by IOSCO based on their data-driven business models. Regulators should consider the degree to which regulated firms can control these platforms and other unregulated intermediaries/service providers.
• Regulators should ensure their own registries are transparent and fully up to date, and adopt technical measures to minimize the opportunities for scams including through fraudulent websites.